FEDERAL GOVERNMENT ICT SUSTAINABILITY PLAN MID-TERM REVIEW

FEDERAL GOVERNMENT ICT SUSTAINABILITY PLAN MID-TERM REVIEW Comments Provided AIIA Response 1 February 2013

INTRODUCTION The Australian Information Industry Association (AIIA) is the peak national body representing suppliers and providers of a wide range of information technology and communications (ICT) products and services. We represent over 400 member organisations nationally, including global brands such as Apple, EMC, Google, HP, IBM, Intel, Microsoft and Oracle; international companies including Telstra; national companies including Data#3, SMS Management and Technology, Technology One and Oakton Limited; and a large number of ICT SME s. AIIA includes a dedicated group of major vendors who form the Association s Environment Special Interest Group (ESIG), and many have worked with the Government in providing input to the finalisation of the current Sustainability Plan under review. ESIG also works with government regulators in Australia and elsewhere to ensure the development of the most appropriate regulatory regimes in all markets in which they operate. Operating in a global industry, all vendors are impacted by regulatory regimes in any jurisdiction. Most ESIG members also engage with the Federal Government as customers. The ICT Sustainability Plan for Government is thus a key platform of interest to these members. AIIA s ESIG comprises: Apple Brother Canon Dell Epson Fuji Xerox Fujitsu HP IBM Konica Minolta Lenovo Lexmark Ricoh AIIA welcomes the opportunity to comment on the mid-term review of the ICT Sustainability Plan, and commends the Department for seeking industry input to the review. General feedback The environmental procurement criteria within the Plan represent a powerful tool for driving continual improvement in environmental performance of Australian Government organisations and delivery of goods and services to the community, and for lifting the environmental performance of the ICT marketplace in Australia, given effective implementation.

AIIA members commend the Plan s adoption of EPEAT Silver as the environmental standard to be applied to ICT (outlined in Section 2) while recognising the presence of other established regional and international eco-labels that meet the ISO standards which are relevant to the ICT industry and can be considered at least equivalent to EPEAT. These include independently certified (IC) eco-labelling programs that are constituents of the Global Ecolabelling Network (GEN). EPEAT standards are progressive, and current iterations are much more challenging to manufacturers than previous ones, even at the baseline Bronze level, because of their comprehensiveness and in some instances, groundbreaking nature. Manufacturers take time to roll these criteria into product design and certification to EPEAT, and it will take a couple of years before there is a sufficient pool of product choices (meeting Silver and even Bronze) available for purchase. For this reason we suggest the Government does not restrict purchases to higher tiers in EPEAT, but instead considers a more open specification selecting products based on prioritized environmental criteria, such as energy efficiency, product recycled content etc. For the criteria to deliver benefit, they should be derived from the overall environmental priorities of the procuring organization. Organizations drafting procurement criteria will benefit most from aligning criteria with the overall environmental priorities of the organization and from prioritizing green procurement specifications, based on good science and with a focus on the areas of greatest risk for the procuring organization. Procurement criteria that cite a maximum number of requirements and that are rated with the same level of importance risk rejecting many environmentally viable products that would otherwise meet the majority of criteria, but which fail on one minor point. Specific Comments The principle as outlined in the summary of outcomes, strategies and actions on page 6 and throughout the document to encourage the use of ICT technology and innovative solutions for driving more sustainable approaches to the management of government organisations operations and delivery of services is supported. Environmental strategy in ICT does not stop at procurement considerations around hardware alone, although that is important. Innovation around the solution or outcome that drives or improves environmental performance of the area to be managed should be a key consideration. Seamless integration for compatibility and ease of use within the organisation s existing structure and systems is also key. This may include comparing hardware ownership vs leasing arrangements vs cloud computing for example. Data analytics may also be a crucial area to make timely adjustments to changing performance and external parameters that impact the meeting of performance towards sustainable outcomes. Most manufacturers in the ICT market have global market channels so adoption of international standards, or if needed, country harmonisation standards with the international standard, is always preferable where feasible. The mandatory procurement criteria identified in Section 2.1 for improving sustainable procurement are supported as long as government organisations have some flexibility in setting procurement selection criteria. Not all government organisations will be at the same place in their environmental improvement strategy/plan/journey and different organisations may have different significant environmental aspects that need to be addressed. Allowing each organisation to develop its own weighting system for the mandatory

and key voluntary environmental procurement selection criteria is supported as discussed in Section 2.2. Provision of a standard template for the weighting system may promote consistent approaches for like organisations. Further comments on the mandatory environmental standards are: ES1 - IEEE 1680 series standard used as a base for the EPEAT program provide a good coverage of environmental attributed for electronic equipment which are also generally acceptable internationally to the ICT industry. The ISO 140021 and 140024 standards for environmental labeling information for third party product certification are comparable. As noted on page 11 of the Plan EPEAT is working on including specifications for computer servers. Standards generally build in continual improvement in performance though formal review processes to revise and add necessary targets / goals. Refer to the relevant standard and listing an attainable rating level for the industry i.e. Sliver for EPEAT, is supported, rather than being more specific on key environmental attributes or providing quantitative targets. ES2 - Listing voluntary ENERGY STAR specification may not be needed for all types of equipment if incorporated for that product under EPEAT or a GEMS Determination e.g. GEMS (EPS) Determination or future determinations for computers and computer monitors. By way of a comment a NABERS tool for data centres is due for release by the Government this year and perhaps should be included in the criteria. US EPA ENERGY STAR also have initiatives for promoting energy efficiency in data centres - ENERGY STAR specifications (V1.0) for computer servers and enterprise servers, and working on storage and UPS. There is also an intention to develop a code of conduct for data centres similar to European Union Code of Conduct for Data Centres. GreenGrid also have developed a number of performance metrics for data centre energy and water use efficiency if this is preferred over a data centre code of conduct. ES3 - Product end of life management solutions are supported. Suppliers should be able to show participation, where relevant, in voluntary, co-regulatory and/or mandatory product recovery and recycling programs for IT equipment and consumables. For regulated products such as computers, suppliers should be able to indicate their participation in the National Television and Computer Recycling Scheme. Outright purchase and leasing arrangements should address and include maintenance services and asset management and disposal service are key considerations to extend the useful life of equipment. For consumables such as toner cartridges and bottles, users should expect access to suitable product return programs. IT maintenance services could cover certified parts replacement that utilise used and new replacement parts. ES4 - General use office paper post-consumer recycled content of 50% or more is supported. However, it may also be suitable for the supplier to be able to warrant that the source material comes from sustainably managed forests, where feasible. Paper manufacturing facilities that are certified to a voluntary environmental standard such as ISO 14001 are a consideration. ES5 - The supplier s participation in the Australian Packaging Covenant (possibly a national co-regulatory scheme in the near future) or the Used Packaging Materials Measure is supported, however there are situations where a supplier may be exempt so being able to demonstrate implementation of suitable sustainable packaging requirements such as the Sustainable Packaging Guidelines supported by APC should be considered as a minimum requirement for the procurement criteria.

ES6 - Adoption of an environmental management system that is at least aligned with ISO 14001 EMS 2004 standard is supported as a suitable tool for driving improved environmental performance of suppliers, and possibly the ICT marketplace in more general terms. Allowing flexibility for adoption within a certain time frame is also supported. Having flexible conditions to allow a supplier to secure compliance to mandatory environmental standards within 6 months or similar as agreed between the two parties may be worthwhile this gives smaller suppliers with innovative solutions a foothold to compete in the environmental /sustainability area for government business. Further, when targeting key environmental standards for adoption in government procurement directives and guidance documentation, it is important to recognise that there may be similar or equivalent standards that a supplier has subscribed to that will equally fulfill the procurement criteria of the government organisation. Flexibility should always be maintained in any mandatory directive or procurement criteria to allow for the supplier to demonstrate they meet the mandatory procurement criteria in other suitable ways. Government Performance to Plan While AIIA supports the ICT Sustainability Plan (henceforth referred to as the Plan) as a catalyst to improve the environmental performance of ICT in Australia, individual members have conducted a number of studies into the area of ICT sustainability maturity and have noted that Australian green ICT practices stalled in 2011 and declined slightly in 2012. One such study has been commissioned by a member of AIIA s ESIG, and conducted by Connection Research and using a jointly developed CR and RIMT model to interpret the results / judge maturity. The study determines a score for each area of this model (see over) and also an overall maturity score with a maximum being 100 and best practice being 80 and above.

This global research suggests that Australia may be falling behind other countries. The Australian data show that Government is the best performing industry with a score of 53.7 but that this is still well short of best practice (80). The best performing area is Enterprise and the least well performing area is Metrics. See below.

Comparisons between 2012 and 2011 show that all scores in all areas of the maturity model went backwards in Government, with the greatest fall being in Lifecycle. Australian Governmnent ITSx Performance 2012 vs 2011 2012 56.3 54.3 58.3 52.8 46.7 43.7 2011 62.3 56.3 59.1 53.2 50.9 55.5 AIIA believes that the ICT Sustainability Plan outlines a solid approach to addressing the environmental impact of IT in Government and notes this empirical research suggesting that adoption of the plan is low or is failing to achieve its stated objectives. Member feedback also suggests that most agencies do not know ICT energy consumption or ICT energy cost. This is something that the above research suggests has not been addressed with Metrics being the lowest performing area of the model. It could be beneficial to explore the governance mechanisms in the Plan to ensure that agencies are compliant. One of the stated aims of the Plan was to have a Whole of government ICT energy consumption target (20% is mooted in the plan). It is unclear to us if this target was set. If it was, was it published and how is the Government tracking against this target? This extract, taken from the Whole-of-Government ICT Sustainability Plan Discussion Paper published in September 2009 suggested that a target would be established and that large Agencies (budget of 20m+) will have to have an energy management plan. Box 4: Whole-of-government ICT energy consumption target proposed steps 1. DEWHA, in consultation with AGIMO, develops an ICT energy management plan template for agencies including ICT equipment categories and energy consumption methodologies in consultation with agencies. 2. DEWHA analyses energy management plans and targets established by agencies that have ICT expenditure over $20 million. Agency ICT energy management plans are due to be completed by March 2010. 3. DEWHA establishes whole-of-government ICT energy consumption baseline (Year 0) using information and data collected from large agencies energy management plans. 4. DEWHA collects energy management plans from large agencies analyses and

consolidates energy efficiency savings. 5. DEWHA accounts for business growth, ICT market shifts, CPRS, government sustainability initiatives, and other external energy demand variables. 6. DEWHA establishes a whole-of-government ICT energy efficiency target. Industry evidence shows that only around 10% of tenders are including the procurement standards outlined in the Plan. In conclusion AIIA believes that the principles, objective and approach outlined in the ICT Sustainability Plan still seem appropriate and commendable. Members indicate the procurement guidelines have not been applied rigorously to all tenders and it is unclear if the area of sustainability has been allotted the weighting recommended in the Plan. Further, evidence suggests that the measurement and achievement of targets by departments has not been achieved to Plan and AIIA suggests the plan may need improved governance structures and or review/ enforcement to ensure that it is on departments agendas and included in their approach to ICT. To that end we welcome this midterm review as a chance to assess progress and encourage greater participation of government departments in the full adoption of the Plan.